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Emi Grp. North Am. v. Cypress Semiconductor Corp.

United States Court of Appeals for the Federal Circuit

September 21, 2001, Decided

00-1508

Opinion

 [***1424]  [*1344]   RADER, Circuit Judge.

After a jury verdict, the United States District Court for the District of Delaware denied EMI Group North America, Inc.'s motion for a new trial. EMI Group N. Am., Inc. v. Cypress Semiconductor Corp., 104 F. Supp. 2d 370 (D. Del. 2000). Because the district court did not abuse its discretion in determining that the jury verdicts were consistent, this court affirms.

EMI also sought a judgment as a matter of law [**2]  (JMOL) that United States Patent Nos. 4,826,785 (the '785 patent) and 4,935,801 (the '801 patent) are not invalid. The district court denied the motion in part. Because a reasonable jury could conclude on this record that claim 1 of the '785 patent and claims 1 and 5 of the '801 patent are impossible, this court affirms the district court's denial of EMI's motion for JMOL.

The district court granted in-part EMI's motion for JMOL that the '785 and '801 patents are not invalid for obviousness or anticipation. Because the district court erred in finding that the mechanism recited in the asserted claims is not inherent, this court reverses the district court's partial grant of EMI's motion for JMOL.

The district court also denied in-part EMI's motion for JMOL that Cypress Semiconductor Corp. infringed the asserted claims of the '785 and '801 patents. Because we find that the claims of the '785 and '801 patents are invalid, this court does not reach the issue of infringement.

The present case features metallic fuses for semiconductor chips. Due to manufacturing complexities, semiconductor chips typically have redundant circuitry. Manufacturers test each chip to determine whether [**3]  portions of the chip are dysfunctional. Manufacturers then disconnect the dysfunctional portions and the redundant circuitry takes over the function. With this method, the manufacturing process yields a greater percentage of viable chips.

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268 F.3d 1342 *; 2001 U.S. App. LEXIS 20717 **; 60 U.S.P.Q.2D (BNA) 1423 ***

EMI GROUP NORTH AMERICA, INC., Plaintiff-Appellant, v. CYPRESS SEMICONDUCTOR CORPORATION, Defendant-Appellee.

Prior History:  [**1]  Appealed from: United States District Court for the District of Delaware. Judge Roderick R. McKelvie.

Disposition: AFFIRMED-IN-PART and REVERSED-IN-PART.

CORE TERMS

fuse, layer, metal, patent, explosion, recited, district court, interconnect, prior art, laser, invalid, asserted claim, discloses, absorptive, optically, anticipated, upper, refractory, cap, manufacturing, vapor-induced, infringe, melt, energy, laws of nature, jury verdict, new trial, impossibility, forming, removal

Civil Procedure, Appeals, Standards of Review, General Overview, Patent Law, Jurisdiction & Review, Subject Matter Jurisdiction, Appeals, Judgments, Relief From Judgments, Motions for New Trials, Trials, Judgment as Matter of Law, Jury Trials, Verdicts, Inconsistent Verdicts, Jury Instructions, Specifications, Enablement Requirement, Utility Requirement, Proof of Utility, Defenses, Patent Invalidity, Claims, Claim Language, Nonobviousness, Elements & Tests, Utility Patents, Process Patents, Principles & Results, Anticipation & Novelty, Elements, Computer Software & Mental Steps